Legal Opinion

Phillips v. Commissioner

United States Tax Court

Decided February 29, 2000No. 9354-96Published

Ps were limited partners in several partnerships with the same designated tax matters partner (TMP). At the request of the Internal Revenue Service (IRS), the TMP executed Forms 872, Consent to Extend the Time to Assess Tax, extending the periods of limitations for the years in issue. Before executing the extensions, the TMP had been the subject of criminal tax investigations by the IRS. The tax investigations ended before the TMP executed most of the extensions.

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Ps were limited partners in several partnerships with the same designated tax matters partner (TMP). At the request of the Internal Revenue Service (IRS), the TMP executed Forms 872, Consent to Extend the Time to Assess Tax, extending the periods of limitations for the years in issue. Before executing the extensions, the TMP had been the subject of criminal tax investigations by the IRS. The tax investigations ended before the TMP executed most of the extensions. Ps alternatively contend: (1) That the second and third sentences of sec. 301.6231(c)-5T, Temporary Proced. & Admin. Regs., 52 Fed.…

1Opinion of the Court

RICHARD K. AND MARILYN J. PHILLIPS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Phillips v. Commissioner

No. 9354-96

United States Tax Court

114 T.C. 115; 2000 U.S. Tax Ct. LEXIS 13; 114 T.C. No. 7;

February 29, 2000, Filed

River City Ranches No. 4 v. Commissioner, T.C. Memo 1999-209, 1999 Tax Ct. Memo LEXIS 243 (T.C., 1999)

A decision based on the stipulation of the parties will be entered.

Ps were limited partners in several partnerships with the

same designated tax matters partner (TMP). At the request of the

Internal Revenue Service (IRS), the TMP executed Forms 872,

Consent to…

2Cases cited15 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. Crane v. CommissionerSupreme Court of the United States · 1947
  3. Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
  4. Computer Programs Lambda, Ltd. v. CommissionerUnited States Tax Court · 1987
  5. Eleanor Duke v. University of Texas at El PasoCourt of Appeals for the Fifth Circuit · 1981

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